Natasha’s Law is due to be implemented in October 2021. An important development in helping prevent the serious effects of food allergies, this law deals with labelling products that have been packed on premises ready for sale.
Who does it affect?
Any business that is
preparing, packing and selling food from the same premises, or food that is
packed centrally and sold from a mobile stall or vehicle
When does it come
October 2021 in
England, but other UK nations are expected to follow shortly after
What foods are
covered by the new law?
Any food which is
Pre-Packed for Direct Sale (PPDS); that means made by staff in-house, wrapped
or placed in packaging and then put on display. This could include products
like sandwiches, salads, snacks and cakes.
What must we do?
All PPDS products
will need to clearly display the name of the food and a full list of all
ingredients. Any named allergens (from the 14 named allergens list) must be
highlighted within the ingredients list, for example by printing them in bold
or a different colour.
What are the
penalties for non compliance?
to follow the new rules could face a fine of up to £5,000 per offence.
Any business who is selling or planning to sell pre-packed foods would be sensible to consider their operations and processes now, in order to allow all required changes to be in place and tested before October 2021. As well as considering the physical labelling requirements, food businesses will also need to think about staff training implications. Whilst the new law makes information more readily available and therefore easier for staff to communicate accurate information, a key message for all staff in food preparation is the importance of consistency in and clear communication of ingredients and recipes.
Every food business in the UK has a legal responsibility to:
make sure food is safe to eat
make sure it doesn’t add, remove or treat food in a way that makes it harmful to eat
A very important part of fulfilling this legal duty is creating a Food Safety Management system, using the principles of Hazard analysis and Critical control points (HACCP). HACCP is a system that helps you identify potential food hazards and introduce procedures to make sure those hazards are removed or reduced to an acceptable level.
These procedures will help you produce and sell food that is safe to eat, providing you:
keep up-to-date documents and records relating to your procedures
regularly review your procedures to ensure they reflect what you produce or how you work
Creating a HACCP Food Safety Management System
To create a comprehensive food safety management system, you will need to consider the entire journey of the food you produce, starting with the source of your ingredients and covering areas such as food handling, storage, cooking, cleaning and staff training.
A great resource to help you with this is the Safer Food, Better Business resource provided by the Food Standards Agency. This book walks you through each area of your business and tells you what you need to look out for, what records you need to keep, and how often you need to review your processes.
Safer Food, Better Business highlights the importance of good record keeping when producing food that is safe to eat. Good records will instil a culture of diligence within your food business and will also help prove to an EHO that you are doing things right.
The key records that most food businesses will need to keep are:
Delivery Schedule, showing that temperature, dates, packaging and labels are checked for all food deliveries
Ingredients listings, including the 14 listed allergens
For more information, The Safer Food Group offer a Level 2 HACCP awareness course that looks into each area of Food Management in closer detail, explaining how to get it right – and what can happen when you don’t!
You might think that getting your food business allergy safe is a hassle – but think about the consequences of being careless with ingredients that have the potential to kill. If you put the right processes and procedures in place and everyone follows them, you can be sure you are doing your best to keep your customers, your kitchen and your reputation safe.
Ensure that you have adequate food allergy training to fully understand the risks of allergenic ingredients and the best practice you must use to ensure a safe business. This is not as simple as just keeping peanuts out of your kitchen!
Step 2 – Ingredients Audit
Be aware of every ingredient that you use in your kitchen, whether cooked in house from individual ingredients or pre-prepared. For every element of every dish, make a list of all ingredients and highlight the 14 known allergens.
Tip: Don’t forget drinks, condiments and sauces – did you know that malt vinegar contains gluten, for instance?
Step 3 – Process walk through
Walk through the entire ‘life’ of a dish in your kitchen – from delivery, through storage, preparation, service and clean down, considering what would happen if an allergen was present in that dish. Identify points where cross contamination could occur, and how you can prevent it by measures such as:
Separated storage and prep zones for allergens
Clear identification of specially prepared meals during service
Efficient clean down and separate pot wash routines
You may decide that you cannot guarantee that allergenic ingredients can be eliminated from dishes – if that is the case, you must communicate this to your staff and customers, to allow them to make informed decisions about their food.
Step 4 – Write it down!
Once you’ve completed the walk through and decided what you will do to keep allergens isolated, you must write it down in a clear, logical way that can be followed by any team member involved in any stage of the process.
Once you have gathered all of the vital information, you have to pass it onto the relevant staff. Think about different roles in your business and their contact with allergens, as well as their contact with customers
Train your staff clearly in the processes they need to follow when working with allergenic ingredients. It is useful for front of house staff to have an understanding of food prep process, and food prep staff to understand how the front of house team operates. Create a culture in which they are happy to ask questions and seek advice if they don’t understand or have forgotten their training.
Think about how you retrain your staff when dishes, processes or legislation changes, and how often you refresh their training.
It is vital that you include allergen training in your induction programme for new and returning staff.
Consider the clearest ways in which you can communicate ingredients info to customers. It is a legal requirement to communicate the details of which dishes contain the 14 listed allergens, but some customers have allergies that are not covered by the list, and being able to inform them accurately of all ingredients in all dishes will help your reputation as a responsible business.
The key message for you and your staff when it comes to communication is NOT TO GUESS THE ANSWER TO AN ALLERGEN QUESTION. ’I don’t know’ is always an acceptable answer, if the member of staff then seeks out the correct piece of information. Teach your staff:
The Food Standards Agency have announced the launch of their ‘Here to Help’ Guide, aimed at small and new food businesses adapting to the current situation.
The FSA say,
‘In order to continue operating during COVID-19, many established food businesses have diversified into food delivery, takeaway or online sales. There has also been an increase in people cooking from home and selling food locally or online.
The Food Standards Agency are offering support and guidance to established and new businesses to help address the challenges of the COVID-19 pandemic.
The Here to Helpcampaign will provide guidance and promote best practice to support food businesses to stay compliant with food hygiene and safety requirements and best respond to the impacts of COVID-19.’
It is no exaggeration to say that the last 6 months have been the most unusual we have experienced. Underlined with uncertainty and fear that has invaded our home and professional lives, we have all done our best to adapt to the new circumstances and work towards a future we were not expecting.
Some sectors of the food industry have had an incredibly tough time – for instance the number of vacancies in catering advertised in July was down 61% compared to 2019, reflecting the fall out from closed venues, reduced capacity and cancelled events. Some sectors however, have managed to thrive – adaptable players in food manufacture have been responsive in light of supply issues during the early stages of lockdown, choosing new products, production methods or packaging to meet the needs of a rapidly changing market.
So, how can we be more prepared for the next 12 months in the food industry? We look at three key predicted trends, and consider their potential impact.
Reversing the obesity crisis
We have already seen the early signs of an upcoming government initiative to change the course of the obesity crisis. Research published by Diabetes UK has demonstrated the link between lockdown and increased rates of obesity in children, and an evidence review by Public Health England strongly suggest that outcomes of Covid-19 are worsened in obese adults.
It remains to be seen what role the food industry will play in battling the obesity crisis, but now is a great time for businesses to plan for the future and consider ways they can demonstrate their commitment to the health and well being of their customers. These may include:
reformulating products to lower fat, sugar and salt levels
publishing nutritional values on menus and / or websites to encourage healthy choices
creating healthy eating promotions and recipes
Strengthening the Supply chain
Initial stages of lockdown exposed some weaknesses in the food supply chain – however, manufacturers and food retailers worked tirelessly and effectively to get products back into stores and homes. Despite this being an unprecedented situation, that early period forced food businesses to reassess the suitability of supply processes.
A number of trends have begun to emerge from this work, and we will continue to see changes throughout the next 12 months, emphasised by the potential supply issues caused by Brexit. The trends have included:
a greater emphasis on local, seasonal produce – with the additional benefit of decreased environmental impact
a more considered and collaborative use of resources in food production – for instance sharing plant facilities or warehousing space, or multi purposing production lines
increased scrutiny on safe production processes, including good health and well being of industry workers in light of covid spikes centred around production facilities.
Now more than ever, good practice at all stages within the food chain will place business in the best position to take advantage of new market opportunities, maximising their potential to survive and grow.
Rising success of the small food business
The economic situation is undoubtedly tough for all food businesses, especially those without a corporate safety net to keep the cash flow going. However, lockdown has demonstrated how agile and adaptable small businesses have been and continue to be as the rules and landscape shift on a weekly business
Some great examples of small business agility have been:
Pubs and restaurants adjusting their eat in offering to takeaways or meal box options
Food retailers taking their sales out into their community, using church halls, delivery services, or even repurposed ice cream vans to get supplies to vulnerable people
Businesses recognising and solving community problems – including the micro brewery who provided a reciprocal collection service for food bank items donated by customers of their delivery service. Community engagement has been a strong theme for a lot of food businesses, giving them the opportunity to really get to know and build relationships with their customers, and there is no doubt a number of these initiatives will continue and thrive once the threat of the pandemic has lessened.
Artisan producers joining forces to create ‘lockdown luxury’ boxes – sharing storage, packing and delivery resources to reduce cost and environmental impact and increase customer base
Small businesses can suffer from higher proportional overheads, without the economies of scale enjoyed by larger companies. However, they often have the benefit of entrepreneurial spirit, an adaptable and loyal staff body and the agility to change direction quickly and make change happen. In these adverse times, these skills will continue to be invaluable and as circumstances develop, the rise of small businesses is very welcome .
There is no one simple answer to the question, ‘Do I need a Food Hygiene Certificate’ – but we can certainly help find the right answer for you.
If you are responsible for managing food safety in a business – for example, a supervisor, manager or business owner – you must be suitably trained to ensure you can put correct procedures in place and see they are carried out. You must also ensure that your team is appropriately trained in food hygiene and safety, including allergens.
If you are someone who works with food, you must be trained to a suitable level for your role, in food hygiene and safety, including allergens.
But – what is suitable or appropriate training?
The Food Standards Agency define training as:
training while working
relevant previous experience
So, technically, neither a supervisor nor their team requires a food hygiene certificate to operate safely and satisfactorily. However, it is worth bearing in mind that training is a key area that your EHO will look into, and it is very likely that any inspection will include a number of questions both to management and team members to satisfy the inspector that good food safety is understood and carried out. For that reason, it is good practice for all food handlers and managers to regularly undertake regulated food hygiene training and to renew on a regular basis.
For supervisors, managers, and anyone else who oversees activities and staff and is responsible for introducing and maintaining procedures and processes, it is important that training includes management level skills, for example creating and using a Food Safety Management system. In general in the UK these would be Level 3 courses – although it is always important to check the syllabus of any course you undertake, to ensure you cover all the important elements.
For food handlers – including chef, cooks, anyone in food prep and front of house staff – a Level 2 Food Hygiene certificate should cover day to day needs – although again, we would always recommend checking the syllabus of any course before you sign up. A Level 3 Certificate would be a good way to increase skills and knowledge and demonstrate readiness to take the next step into management
For anyone who doesn’t directly handle food, but an understanding of food safety is important, a Level 1 Food Hygiene Certificate can provide the basic level of training required. This training might be useful for someone making food deliveries, or a kitchen porter.
For all regulated food training, we would recommend retaking the course every 3 years. As well as refreshing knowledge, this gives the learner insight into any new practice or legislation influencing food hygiene practice introduced since their previous training.